Subject: File No. S7-14-08
From: Pete Tychsen

October 21, 2008

Dear Sirs,
I am strongly against Fixed Indexed Annuities becoming a security for a couple of reasons.
First, I honestly do not believe they are securities. They have a guarantee of principal and do not fluctuate in value. Second, they are already regulated by the state departments of insurance.
Please reconsider your position.
Many Thanks,
Pete Tychsen